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The answer of Patrick H. Jackson to a bill of complaint exhibited in the Circuit Superior Court of Law & Chancery for Prince Edward County by Henry Jackson suing by his guardian and next friend Pleasant Labby against Patrick H Jackson John H Smith & others For answer to the said bill the said Respondent Patrick H Jackson reserving to himself the benefit of all exception to the errors deficiencies and informalities of the said bill says that it is true that in or about the year 1842 James M Jackson duly executed and had recorded in the Clerks Office of Prince Edward County Court the deed of trust mentioned in the complainants bill and which is also here referred to and prayed to be deemed a part of this answer, that the object of the said deed was to secure the payment of a large amount of money about $20,000 due to branch of the Farmers Bank of Va located at Farmville and particularly to secure the endorsers on the note by which the said debt were evidenced, of which notes this Respondent was the first indorser, that of the property conveyed by the said deed of trust the three negro slaves now claimed by